United States v. Mezzanatto

Mezzanatto (defendant) was arrested on drug charges after selling methamphetamine to an undercover cop. Mezzanatto and his attorney met with the prosecutor to discuss cooperating with the authorities. The prosecutor told Mezzanatto that he had to agree that any statements he made during the discussion could be used to impeach any inconsistent statements he might make at trial. Mezzanatto talked with his attorney and then agreed to this condition. During discussions, Mezzanatto admitted knowing that the package he sold to the undercover cop had drugs in it. He also admitted knowing about a meth lab at the home of a man named Shuster. Later, at trial, Mezzanatto denied knowing that the package contained drugs and denied knowing about Shuster’s meth lab. On cross examination, over the objection of Mezzanatto’s attorney, the prosecutor asked Mezzanatto about the prior inconsistent statements he made at their earlier meeting. Mezzanatto was found guilty. The appellate court reversed his conviction and held that Mezzanatto’s agreement to allow statements made during plea bargaining to be used for impeachment at trial was unenforceable. Federal Rule of Criminal Procedure 11(e)(6) and Federal Rule of Evidence 410 (the plea bargaining rules) exclude statements made during plea bargaining from being used as evidence at trial. The appellate court held that these rules’ exclusionary provisions cannot be waived. The Supreme Court granted certiorari.